Final Notes on January 2013 AAFCO Meeting

The following are little bits and pieces of information from the recent AAFCO meetings.

Different requirements for human food than animal food
The example given during the meeting was blisters found in the mouth of a cow. If a veterinarian sees this/treats this animal, he/she is legally required to report this to State authorities. The reason…this could be a serious illness that could spread quickly to thousands of cattle or harm human health.

However the same is not required of a veterinarian that sees/treats a dog or cat in kidney failure (or other diseases that could be linked to a pet food/treat). In fact, few small animal veterinarians know how to report an adverse event to FDA or State Department of Agriculture. Further, small animal veterinarians are not provided with on-going education to diagnose a pet food or treat adverse event. To me, this is something that needs to be addressed by FDA. Education – on-going education needs to be provided to practicing veterinarians on how to diagnose, treat, and report a pet food/treat adverse event. Countless lives could be saved with such an effort.

GMO labeling
Regarding the forty minute presentation from the Pet Food Institute, the American Feed Industry Association, and the National Grain and Feed Association against the labeling of GM (genetically modified) ingredients – it is my opinion there was a significant reason these organizations were working the crowd (a crowd of federal and state regulatory authorities). My guess is they are behind the scenes quietly pushing forward legislation to exclude animal feed/pet food from GM labeling laws that will ultimately happen in each state. These organizations presented all negative opinions to GM labeling – my guess – to ‘work’ the AAFCO members; hoping to achieve laws excluding animal feeds/pet foods from GM labeling into the Official Publication (book of model bills accepted by states) before any particular state requires GM labeling of all foods. Then pet food consumers won’t be informed to the genetically modified ingredients in their pet foods.

For those that support GM labeling, this is something we must watch closely.

I felt it was inappropriate of AAFCO to allow such a presentation at the regulatory meeting. This was no place for a forty minute attack against GM labeling of foods. However, since AAFCO allowed this biased presentation to occur, AAFCO should allow a 40 minute opposing opinion presentation at the next meeting (I publically asked for equal time). Time will tell if AAFCO wishes to play fair.

Changing laws to make illegal pet foods legal
The FDA representative discussed adding several ingredients into AAFCO’s Official Publication (OP) because there was no official definition for these ingredients (which would make them illegal). She shared that FDA had been allowing these ingredients in pet foods for several years (did not enforce law) and FDA wanted the OP to be updated with these various ingredients – making those that use them legal.

My thinking was – this was ridiculous. Why change laws to play catch up with illegal pet food ingredients? Why not enforce law and remove these pet foods from store shelves until various ingredients have an official definition?

The sensible way is not the pet food regulatory way.

Carbohydrate percentage on pet food labels
The AAFCO Carbohydrate Working Group is still working on what the Guaranteed Analysis statement on pet food labels should state regarding carbohydrate percentage of the pet food. Hopefully they will have this information by the August meeting. The bad news is that once this group puts together how carbohydrate information should be stated on a pet food label, then the discussion will begin on exactly how long manufacturers will need to become compliant. If this is anything like calorie statements on pet foods (actually, I suspect this will be worse), I’d guess we are at least ten years away from seeing required carbohydrate information on our pet food labels. Very discouraging.

Dyes to become ‘pigmentation’ or ‘color additives’
It was noticed during one discussion that food dyes were referenced as pigmentation and color additives. It is a guess that manufacturers and ingredient suppliers are wishing to end the use of the term ‘dyes’ because they are commonly known as risks. Changing the wording could result in changing the petsumer perception.

Ingredient Descriptors
It was wonderful to hear a State Department of Agriculture representative (and AAFCO member) complain that she wants to put an end to ingredient descriptors – add on words that are not officially legal. The example provided was with the ingredient ‘peas’. ‘Peas’ are defined in the AAFCO OP, but pea starch, pea protein, and so forth are not. You’ll see many pet food labels using the non-approved ingredient descriptors. There was introduction of a future model bill (future law) that would not allow these types of ingredient descriptors. Three cheers for this one! Ingredients should be used and listed as is required by law – and nothing more.

The January AAFCO meeting – needless to say – was a busy event. There is much work ahead of us. The next meeting will be held in August – in my area of the country, St. Petersburg, Florida.

What is the BFD about informing customers the truth about the products we buy? Why are misleading labeling allowed? Why is the FDA on the side of companies? I though the FDA was on our side. Don’t we pay their salaries?

And are the companies stupid? As word gets out about their lying people will not trust their name. I speak to more and more people who make their own beloved pet’s food because they have realized they can no longer trust the Big Pet Food Companies.

If ingredient descriptors such as those used for peas are not defined by the AAFCO what does this mean? Some of the foods I feed my dogs contain pea starch and pea protein – does this mean pea starch could not be pea starch or pea protein could not be pea protein?